Bissonnette v. LePage Bakeries Park St., LLC

This case was decided by the Supreme Court of the United States on April 12, 2024. The plaintiffs, Neal Bissonnette and other delivery drivers, worked for LePage Bakeries Park St., LLC, a company that produces and distributes baked goods. The drivers filed a wage-and-hour lawsuit, but the company moved to compel arbitration based on the drivers' employment agreements. The drivers argued they were exempt from the Federal Arbitration Act as transportation workers engaged in interstate commerce. The district court and the Second Circuit ruled in favor of the company, holding that the exemption applied only to workers in the transportation industry, not to transportation workers within other industries. The Supreme Court reversed, unanimously holding that the Section 1 exemption of the FAA is not limited to workers in the transportation industry, but applies broadly to any worker engaged in interstate transportation, regardless of their employer's primary business.

The Supreme Court unanimously reversed the Second Circuit's decision. Chief Justice Roberts delivered the opinion of the Court, holding that a transportation worker need not work in the transportation industry to be exempt from the FAA under Section 1. The exemption turns on the work the employee performs, not the employer's business. The case was remanded for further proceedings consistent with this interpretation.

The central dispute was whether the Section 1 exemption of the Federal Arbitration Act, which exempts contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce, applies only to workers whose employer is in the transportation industry, or to any worker performing transportation work across state lines regardless of the employer's industry classification.

This ruling significantly expands the pool of workers who can avoid mandatory arbitration and bring collective lawsuits in court. It limits the power of employers across various industries, such as retail, manufacturing, and food service, to compel arbitration for delivery drivers and other transportation workers. The decision promotes workers' access to judicial forums for wage and labor disputes, potentially altering the balance of power in employment litigation and encouraging more class-action lawsuits over wage-and-hour claims. It clarifies the legal landscape by focusing on the nature of work performed rather than the nature of the employer's business.